1. CONTROLLER:

2. NAME OF THE REGISTER

3. LEGAL BASIS OF PROCESSING OF THE PERSONAL DATA

The processing of the personal data included in the register is based on:

consent the data subject has given when registering; and

customer relationship between the controller and the data subject, for which purpose the processing of the personal data is necessary.

4. PURPOSE OF THE REGISTER AND PERIOD FOR WHICH THE DATA WILL BE STORED

The personal data will be processed for the purposes of delivering the devices, billing, marketing, tending the customer relationship and statistics and developing and producing devises and services and for enabling the contacting necessary for providing the service such as informing about possible cancellations.

Data regarding the customer relationship will be stored as long as it is necessary for the purposes of said customer relationship or for preparing for potential reclamations. Event and usage information will be stored 6 -24 month, depending of the event and subject.

In addition, the customer information included in the register may be used for Vivago Ltd’s marketing, research purposes, and for organizing competitions. The customer has a right to object at any time the processing personal of data concerning him or her for marketing purposes by notifying this in writing to the controller by email to info@vivago.com or by mailing the notification to the address provided in section 9.

5. DATA INCLUDED IN THE REGISTER

The register includes personal data of the customers of Vivago and/or of the persons registered as users in Vivago Ltd’s online services. The following data will be processed:

Name and contact information of the data subject

Demographical information

Information related to consents and refusals

Identification and user information

Information related to the use of electronic services and content (e.g. subscription of newsletters), technical information provided by the data subject’s web browser (e.g. IP-address, browser, browser version, page from which the data subject has moved to our page)

Other information provided by the data subject

Event and analysis information

Information related to patronage or membership (e.g. subscription and cancellation information related to paid goods and services, subscription information related to free goods and services, copies of reclamations and customer service sessions, such as phone calls, emails, chat- and text messages)

6. SOURCES OF INFORMATION

The information is provided directly by the data subject in conjunction with registration or in connection to his or her customer relationship. Some of the information (including user information and event and analysis information) are gathered when the data subject is using the services of the controller. The information gathered in the webpages are obtained from the data subject, when he or she fills in a form and in connection with various kinds of marketing events such as raffles and competitions and other such events.

7. TRANSFER OF THE DATA

The data may be transferred on controller’s discretion and within the scope of applicable legislation in force, for instance to controller’s partners, provided that the data subject has not objected to the transfer of his or her data. The data subject may object to the use and transfer of his or her data for marketing purposes. Due to the technical reasons related to the processing the data, some of the data may be physically stored in the servers of the controller’s outside subcontractors and will be processed by means of remote access.

Our web page may contain links to webpages operated by third parties. Vivago Ltd does not take responsibility for the contents or privacy policies of such third-party webpages. We recommend that you familiarize yourself with the privacy policies of each such webpage.

Data will not be transferred outside the European Union of European Economic Community, unless it is necessary due to technical reasons related producing the service. If the personal data included in the register is transferred outside of the European Union or European Economic Community, the controller undertakes to ensure, that the transfer shall be done in accordance with the applicable legislation in force and that the adequate level of protection of the personal data provided by applicable legislation in force will not be jeopardized.

8. PROTECTION OF THE REGISTER

The data will be gathered to data bases common to the service, which are protected with firewalls, passwords and using other technical means. The databases are located in locked and guarded premises and the data may be accessed only by named persons.

9. Rights of the data subject

The data subject has the rights provided in this section. Any communication regarding these rights should be sent to the following address with a written and signed notice:

Vivago Ltd Itsehallintokuja 6 FI-02600 Espoo Finland

Right to access

The data subject has on request a right receive the information regarding the data processed by the controller referred to in article 15 of the General Data Protection Regulation

Right to rectification

The data subject has the right in accordance with article 16 of the General Data Protection Regulation to obtain from the controller the rectification of inaccurate personal data concerning him or her. When necessary, the data subject shall have the right complete incomplete personal data by providing a supplementary statement to the controller.

Right to erasure

The data subject shall have the right to obtain from the controller erasure of personal data concerning him or her, if the personal data is no longer necessary for the purposes provided in this privacy statement, the data subject has withdrawn the consent on which the processing has been based on, or the controller has processed the personal data unlawfully.

Right to restriction of processing

The data subject shall have the right to obtain from the controller restriction of processing in situations referred to in article 18 of the General Data Protection Regulation.

Right to lodge complaint with a supervisory authority

If the data subject feels that the processing of the personal data concerning him or her breached the General Data Processing Regulation, the data subject shall have the right to lodge a complaint with a supervisory authority, which in this case is primarily the Finnish Data Protection Ombudsman.

10. CHANGES TO THE PRIVACY STATEMENT

We reserve the right to make changes to this privacy statement by posting a notice in our web page. We recommend that you periodically review the contents of the privacy statement.

11. CONTACT INFORMATION

The controller of the personal data we collect if Vivago Ltd. the contact person regarding the upkeep and protection of the register is Satu Ruissalo. Any enquiries you may have regarding this privacy statement should be sent to: info@vivago.com